Interpretations and Actions: August 1998

Vol. 11, No. 8

PLEASE NOTE: Interpretive Letters and No Objection Letters reflect the views of the Comptroller's legal staff. Corporate Decisions and Decisions (CRA) are from the office of Bank Organization and Structure. The list of CRA Ratings is from the Communications Division. For copies of the evaluation, you should contact the bank directly or the Office of the Comptroller of the Currency, Attn: Public Reference Room, Mailstop 1-5, Washington, D.C. 20219.

Members of the news media are encouraged to cite the letter number when reporting or summarizing documents from this package. This helps to process single requests in a more timely manner.

Interpretive Letters

Letter concludes that national banks have the authority to purchase performance notes (Notes) in which the yield on the Notes is based upon the performance of a pool of mortgage made by the bank. (07/08/98)

Letter concludes that a national bank's ownership of a non-controlling interest in an insurance company that reinsures mortgage life, mortgage accidental death, and mortgage disability insurance on loans originated by the lenders with an ownership interest in the insurance company is permissible. (08/03/98)

CRA Decisions

Application of First of America Bank, National Association, Kalamazoo, Michigan, to merge with First of America Bank-Illinois, National Association, Bannockburn, Illinois, with the resulting title of National City Bank of Michigan/Illinois; (Control Number 98CE020015), (07/14/98).

Community Reinvestment Act (CRA) Performance Evaluations

INTERPRETATIONS AND ACTIONS is published monthly by the Office of the Comptroller of the Currency. Subscriptions are available at a rate of $175 per year by writing to the Comptroller of the Currency, P.O. Box 70004, Chicago, IL 60673-0004. Prepayment is requested. Suggestions, comments or questions may be sent to Jacqueline J. England, Communications Division, Comptroller of the Currency, Washington, DC 20219.